Yesterday the Environmental Protection Agency (EPA) delivered the message that biomass is part of the climate and renewable energy solution. EPA stated in a memorandum to regional offices that biomass is a renewable energy pathway for states to reach carbon reduction targets under the proposed Power Plan Rule and that the agency will propose that biomass can be carbon neutral in forthcoming amendments to the Tailoring Rule. This action brings EPA into alignment with the White House and the U.S. Department of Agriculture (USDA). All three now acknowledge the significant carbon benefits of forests, wood and biomass. They all "get it" - biomass is good for the climate.

But "getting it" only works if EPA remains focused on the carbon.

EPA's memorandum states that the agency will consider biomass from "sustainably managed lands" as carbon neutral, suggesting that sustainable management yields carbon neutral biomass. That sounds right to the average reader. Forests in the U.S. are among the most sustainable in the world - a fact we are all proud of. However, sustainability in the context of EPA's forthcoming rulemakings requires more careful attention.

"Sustainability" is a broad concept that can encompass everything from environmental to economic to social values. It is a concept that must be bracketed by clear parameters to fit the policy context in which it is applied. If applied out of context in EPA's power plant rules, it could become a condition introducing complexities, costs and legal entanglements that could swallow the rule and all of the biomass with it.

So how does EPA avoid a sustainability tar baby in its treatment of biomass? The answer is relatively simple - focus on the carbon.

Without question EPA will hear plenty of creative ideas about the scope of sustainability including all of the co-benefits the agency could in theory achieve in state implementation plans and permit applications. Many or most of these will have little or nothing to do with carbon emissions and, if adopted, would create the very complexity EPA has vowed to avoid. EPA can avoid the complexity trap by keeping its eye on carbon and carbon only.

Forest owners have repeatedly demonstrated that biomass is sustainable from a carbon standpoint. Forest biomass does not increase carbon accumulation in the atmosphere so long as our nation's overall forest carbon stocks are stable or increasing. Forest carbon stocks in the U.S. have increased by 50 percent in the last 50 years because of sustainable practices that have enabled our forests to both meet the increasing needs of our country and continue to remove net carbon from the air. Looking at EPA's power plant rules through this carbon lens, carbon sustainability is not only the common characteristic of nearly all forest biomass, it is the proven outcome of forest biomass utilization.

Forest owners stand ready to work with EPA to appropriately identify the sustainable carbon benefits of biomass. By remaining focused, EPA can both “get it” on biomass and “get it” right on carbon sustainability.